CABRERA. RADIOLOOICAl.• ENCINEF$1NC• REt.IEOIAnONProtection Plan (RPP). Elevated levels of material will have an isotopic analysis to ensure ... Please contact Mike Winters at

-

CABRERA. $ERY.ICES RADIOLOOICAl.• ENCINEF$1NC• REt.IEOIAnON

May 13,2014

Regional Administrator U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, P A 19406 ATTN: Director, Division ofNuclear Materials Safety

&.3 030353/0

RE: Activities at Temporary Job Site Utilizing U.S. NRC Radioactive Material License #06-30556-01 Amendment 06

Temporary Location: 39 Cherry Avenue, 177 Cherry Street, & 215 Cherry Street, Waterbury, Connecticut

Cabrera Services Inc. (Cabrera) is providing this written notification of its intent to utilize Cabrera Material License #06-30556-0 1 at a temporary job site. Enclosures include the specific information required by License Condition 18A along details of the planned approach to screening of building materials & associated wastes and; an informational copy of the current radiation protection plan for this work, as requested by Todd Jackson, Senior Health Physicist, Commercial and R&D Branch, Division ofNuclear Materials Safety.

We trust that this information is sufficient to grant our use of Cabrera material license #06-30556-01 Amendment 06 at the temporary job site. This license or reciprocity is currently in use at one other site, located in California. No activity exceeding license limitations will be conducted. Cabrera will notify the Regional Administrator, U.S. Nuclear Regulatory Commission, within 30 days of termination of activities at this job site in keeping with license condition 188.

If you should have any questions regarding this notification, please contact Michael S. Winters at (352) 610-2150.

Sincerely,

2014.05.13 12:18:58 -04'00'

Michael S. Winters, CHP Radiation Safety Officer

.. 1-"· --~~,. ::C• ::::;:::

NMSS/RGN1 MATERIALS-002 Enclosures - 2

ENCLOSURE NEW OPPORTUNITIES, INC. (NOI) SITE

CHERRY STREET WATERBURY, CONNECTICUT

(May 2014)

This information is being submitted as required by condition 18A of the Cabrera Materials License.

Cabrera is scheduled to provide health physics services to support activities at the New Opportunities, Inc. (NOI) Cherry Street Site in Waterbury, Connecticut. The Site buildings were formerly part of the Waterbury Clock Company complex where, in the early 1900s, portions of the contiguous buildings were used to paint clock dials with luminescent paint containing radium. The Connecticut Department of Energy and Environmental Protection (CTDEEP) Radiation Division has been involved with the assessment of the Site and determined that building materials in portions of the contiguous site buildings are contaminated with radium.

The Site is occupied by five abandoned industrial-use buildings. Three of the buildings are contiguous buildings composed of 4 to 6 stories that occupy the majority of the Site: the rectangular-shaped building designated as 39 Cherry A venue comprises the western border of the Site, and L-shaped buildings designated as 177 Cherry Street and 215 Cherry Street are perpendicular to the eastern border of Cherry Street. A garage building abuts the northern border of 39 Cherry A venue and a former office/carriage house (0 Cherry Street) stands alone on the southwestern property border. Basement crawl spaces are present on the northern portion of 39 Cherry A venue and the eastern portion of 177 Cherry Street.

Cabrera will implement a radium radiological screening process to support asbestos-containing material (ACM) abatement work to clear out residual debris and materials from floors of buildings on the Site. The screening will determine if wastes that are generated will be disposed as ACM wastes only or require disposal as radium-contaminated ACM.

Prior to asbestos abatement activities, a Cabrera health physics technician (HPT) escorted by an asbestos trained individual will pre-screen the debris piles for the presence of radium using a live-time dose rate instrument (Ludlum Model 2221 ratemeter/scaler with a Ludlum Model 44-20 3-inch by 3-inch sodium iodide [3x3 Nai] probe, or equivalent). Fifty (50) direct total contamination (static) measurements will be taken on each floor within the contracted area at random locations determined by Cabrera HPT' s. In addition static measurements will be taken on oversized and selected debris items using a Ludlum Model 2224 ratemeter/scaler with a Ludlum Model 43-93 alpha-beta scintillation probe, or equivalent.

The HPT will radiologically screen packaged waste debris at a sampling frequency of not less than 10 percent utilizing the Cabrera Large Area Scanning System (CLASS). The screening will be performed on discrete packages with the detection unit in a fixed/reproducible position to ensure optimization of data collected for material screened. Bags of wastes will be scanned at a rate of approximately 3-inches per second with the detector approximately 6-inches from the exterior surface of the bag. Calculations and assumptions for parameters such as bag diameters, total weight of wastes in the bags, detector type and distances, and countrate or doserate

conversiOns to Ra-226 actiVIty in the bags are provided in Attachment 2 of the Radiation Protection Plan (RPP). Elevated levels of material will have an isotopic analysis to ensure accurate information for waste characterization labeling of such waste and for transportation and disposal. Should radium be detected above the project release limit of 3x the established background (200% BKGD [naturally observed background] plus BKGD), screening will be performed more frequently until the radium activity diminishes to project acceptable levels. Items that are too large to be released using the CLASS will be released in accordance with Regulatory Guide 1.86 referenced in section 7.3.4.1 table 7-3 of the RPP. The previously described radiological screening sample rate of 10 percent will also apply to these large items.

Radium activity that is detected in waste materials above the project release limit will be separated from the non-radium contaminated debris. The waste materials are those generated by ACM abatement such as air handling unit filters and other Investigation Derived Wastes (IDW). Radium contaminated debris will be staged in a designated radioactive materials area for later disposal at an approved facility.

Potential radium in the form of loose surface contamination and possible residues from historic radium painted operations would likely be encountered on the exterior surfaces of ACM. Less than 5 millicuries of total radium activity are expected to be handled. In addition, Investigation Derived Wastes (IDW) will be produced during the work evolution. This includes small amounts of contaminated PPE and equipment (gloves, smears, used containers, air filters, etc.). This IDW will be handled in accordance with federal and state regulations. Total IDW is expected to be less than the equivalent of two 55-gallon drums. Cabrera will not take permanent possession of any radioactive materials derived from the Site in excess of our license limits.

Daily QC of radiation detection instrumentation will be with NRC exempt sources. These sources will be controlled under the Cabrera NRC Materials License. Sources will be shipped or hand delivered to the Site directly to a CABRERA Employee. Source controls will be implemented onsite in accordance with Cabrera NRC License conditions. In addition, Cabrera Radiation Safety Procedure "Use and Control of Radioactive Check Sources", OP-009, will be utilized to ensure proper source storage and control.

Cabrera NRC Materials License (No. 06-30556-01) requirements, including previously submitted procedures, will be adhered to with respect to the duration of this work evolution. Radiological surveys of affected work areas, and decontamination of equipment used for the work effort will be conducted after completion of sampling activities to ensure the absence of radioactive contamination. These values are consistent with NRC Regulatory Guide 1.86.

Cabrera will post the most recent NRC Form 3 and supplemental documentation according to 10 CFR Part 19.11 "Posting of Notices to Workers" at the temporary job site.

Work within the current scope of remediation activity including mobilization and demobilization is expected to commence on or about May 29, 2014 with completion by June 27, 2014. Cabrera will notify the NRC within 30 days of completing operations and demobilizing from the site. Ship out of radioactive waste materials staged on site has not yet been determined.

Key project personnel and supporting information:

Title Name Cell Number

Program Manager Rob Flowers (804) 833-7948

Project Manager Chris Wright (860) 919-1691

Corporate Radiation Safety Officer Mike Winters (352) 610-2150

Occupational H&S Manager Sean Liddy (443) 553-1403

Project Certified Health Physicist Hank Siegrist (860) 416-0196

Project Health Physicist Roy Racino (845) 987-6987

SRSL Michael Plonski (860) 794-6915

Health Physics Technicians Jon Cote (860) 305-0048

Nick Berliner (860) 916-6091

Mr. Berliner will serve as the Site Radiation Safety Lead. Mr. Berliner is a listed Authorized User in Cabrera's NRC License condition 11. Others may provide coverage without prejudice as long as they meet NRC License Criteria as provided for in License condition 11. At least one of the authorized users meeting the described requirements will be present onsite during ongoing work activities within the radiologically-controlled area.

Please contact Mike Winters at (352) 610-2150 should you have any questions regarding this Cabrera notification of intent to utilize NRC Materials License, number 06-30556-01.

FINAL, Revision 2

RADIATION PROTECTION PLAN (RPP)

FOR THE

NEW OPPORTUNITIES, INC. (NOI) SITE

CHERRY STREET

WATERBURY, CONNECTICUT

Prepared for: HALEY & ALDRICH 100 Corporate Place, Suite 105 Rocky Hill, Connecticut 06067

Prepared by:

~ .,S,~!.~~~~"~-~~~~~~T~• CABRERA SERVICES INC.

473 Silver Lane East Hartford, Connecticut 06118

Subcontract Number 38563-000

May 2014

NOI Waterbury, CT Site Radiation Protection Plan- FINAL Revision 2 (May 2014)

RADIATION PROTECTION PLAN (RPP) APPROVALS

NEW OPPORTUNITIES, INC. (NOI) SITE Cherry Street

Waterbury, CT

By their specific signature, the undersigned certifY that this RPP IS approved for use during activities at the NOI Site, Waterbury, CT.

APPROVED BY:

• Digitally signed by Roy Racine

R 0 Y R a C I n 0 DN: cn=Roy Racine, o=Cabrera Services, ou, [email protected], c=US Date: 2014.05.13 08:11:32 -04'00'

Roy Racino - Chief Health Physicist, RRPT Cabrera Services Inc.

Chris Wright cn=Chris Wright, o=Cabrera Services, ou=Applied Sciences, [email protected], c=US 2014.05.13 08:39:46 -04'00'

Chris Wright- Project Manager Cabrera Services Inc.

Subcontract #38563-000 CABRERA SERVICES INC.

5/13/2014

Date

5/13/2014

Date

ii

NOI Waterbury, CT Site Radiation Protection Plan-- FINAL Revision 2 (May 2014)

SECTION

1.0

1.1

1.2

2.0

3.0 3_1

3_2

3.3

3.4

4.0

5.0

6.0 6.1

6.2

6.2.1

6.2.2

6.2.3

6.2.4

6.2.5

6.3

7.0 7.1

7.1.1

7.1.2

7.1.3

7.2

7.3

TABLE OF CONTENTS

PAGE

INTRODUCTION ........................................................................... 1-1

Purpose and Objectives ........................................................................................ 1-1

Site Information ................................................................................................... 1-1

ORGANIZATIONAL STRUCTURE ........................................... 2-1

HAZARD ASSESSMENT .............................................................. 3-1

Tasks To Be Performed ....................................................................................... 3-1

Task 2 Activities .................................................................................................. 3-1

Hazard Communication ....................................................................................... 3-2

Radiological Hazards ........................................................................................... 3-2

TRAINING AND RECORDS ........................................................ 4-3

ACTIVITY HAZARD ANALYSIS ............................................... 5-1

SITE CONTROL ............................................................................. 6-1

General Site Access ............................................................................................. 6-1

Radiological Control Areas .................................................................................. 6-1

Radiation Area (RA) ........................................................................................................ 6-1

Airborne Radioactivity Area ( ARA) ............. ..................................................................... 6-1

Contamination Zone (CZ) ................. ............................................................................... 6-2

Contamination Reduction Zone (CRZ) ............................................................................ 6-2

RCA Entry and Exit .......................................................................................................... 6-2

Support Zones ...................................................................................................... 6-2

RADIATION SAFETY PROGRAM ............................................. 7-1

ALARA ................................................................................................................ 7-1

ALARA Tracking .............................................................................................................. 7-2

Contamination Containment ............................................................................................. 7-3

Local Ventilation .............................................................................................................. 7-3

Radiation Work Permits ....................................................................................... 7-3

Radiation Surveys and Monitoring ...................................................................... 7-3

Subcontract #38563-000 CABRERA SERVICES INC. iii


7.3.1

7.3.2

7.3.3

7.3.4

7.3.5

7.3.6

7.4

7.4.1

7.4.2

8.0

8.1

8.2

8.3

8.4

8.5

8.6

9.0

10.0

Survey Methods ................................................................................................................ 7-3

Survey Documentation ..................................................................................................... 7-3

Radiation Surveys ............................................................................................................ 7-3

Contamination Surveys .................................................................................................... 7-4

Air Monitoring ................................................................................................................. 7-7

Radiological Survey Instruments ..................................................................................... 7-9

Personal Radiological Monitoring ....................................................................... 7-9

External Radiation Dosimetry ......................................................................................... 7-9

Internal Exposure Monitoring ....................................................................................... 7-10

LEVELS OF PERSONAL PROTECTIVE EQUIPMENT ........ 8-1

Level D PPE ......................................................................................................... 8-1

Modi fed Level D PPE .......................................................................................... 8-1

Level C PPE ......................................................................................................... 8-1

Decontamination Procedures ................................................................................ 8-2

Personnel Decontamination ................................................................................. 8-2

Personnel Contamination Evaluation ................................................................... 8-4

EMERGENCY RESPONSE .......................................................... 9-1

MEDICAL SURVEILLANCE AND TRAINING REQUIREMENTS ........................................................................ 10-1

11.0 REFERENCES .............................................................................. 11-1

ATTACHMENT 1:

ATTACHMENT 2:

Subcontract #38563-000

ACTIVITY HAZARD ANALYSES

ACM BAG COUNT-DOSERATE-ACTIVITY AND MICROSHIELD RUNS

CABRERA SERVICES INC. iv


LIST OF TABLES

Table 2-1: CABRERA Key Project Personnel ......................................................................... 2-2

Table 3-1: NOI Site ROC ....................................................................................................... 3-2

Table7-1: Site Exposure Limits and ALARA Exposure Goals ............................................ 7-1

Table 7-2: ALARA Formal Job Review Requirements ......................................................... 7-2

Table 7-3: Surface Contamination Limits ............................................................................. 7-6

Table 8-1: Initial Site PPE Requirements .............................................................................. 8-2

Table 8-2: Personnel Contamination Thresholds for Internal Dose Assessment .................. 8-4

Subcontract #38563-000 CABRERA SERVICES INC. v

NOI Waterbury, CT Site Radiation Protection Plan - FINAL Revision 2 (May 2014)

ACM

AHA

A LARA

ALI ANSI

AP

ARA

BKGD

BZ

CABRERA

CFR

CHP

CLASS

em, cm2, cm3

CRZ

CTDEEP

cz DAC

DDE

DOT

dpm

H&A

HASP

HP

lATA

MDC

MeV

mL

mrem/hr

NCRP

NIST

NOI

NRC

OHSMS

OP

OSHA

PE

PHP

ABBREVIATIONS, ACRONYMS, AND SYMBOLS

Asbestos Containing Material

Activity Hazard Analysis

As Low As Reasonably Achievable

Annual Limit on Intake

American National Standards Institute, Inc.

CABRERA Administrative Procedure

Airborne Radioactivity Area

Naturally Observed Background

Breathing Zone

Cabrera Services Inc.

Code ofFederal Regulations

Certified Health Physicist

Cabrera's Large Area Scanning System

centimeter, square centimeter, cubic centimeter

Contamination Reduction Zone

Connecticut Department of Energy and Environmental Protection

Contamination Zone

Derived Air Concentration

Deep Dose Equivalent

U.S. Department of Transportation

disintegrations per minute

Haley & Aldrich

H&A Health And Safety Plan

Health Physics

International Air Transport Administration Minimum Detectable Concentration

Megaelectron Volt

milliliter

millirem per hour

National Council on Radiation Protection

National Institute of Standards and Technology

New Opportunities, Inc.

U.S. Nuclear Regulatory Commission

Occupational Health and Safety Management System

CABRERA Operational Procedure

U.S. Occupational Safety and Health Administration

Professional Engineer

CABRERA Project Health Physicist

Subcontract #38563-000 CABRERA SERVICES INC. vi

NOI Waterbury, CT Site

PM

PPE QA QC

RA 226Ra

RCA ROC RPP

RRPT RSO RSP

RWP SOP SRSL

sso sz 11Ci

a,~,y

Project Manager Personal Protective Equipment Quality Assurance

Quality Control

Radiation Area Radium-226

Radiological Control Area Radionuclide of Concern CABRERA Radiation Protection Plan

Registered Radiation Protection Technologist CABRERA Corporate Radiation Safety Officer

CABRERA Radiation Safety Program Radiation Work Permit Standard Operating Procedure CABRERA Site Radiation Safety Lead

H&A Site Safety Officer Support Zone

microcurie alpha, beta, gamma


Radiation Protection Plan -FINAL Revision 2 (May 2014)

vii


1.0 INTRODUCTION

1.1 PURPOSE AND OBJECTIVES

Radiation Protection Plan --FINAL Revision 2 (May 2014)

Cabrera Services Inc. (CABRERA) has been contracted by Haley & Aldrich (H&A) under Subcontract Number 38563-000 to provide health physics services to support activities at the New Opportunities, Inc. (NOI) Cherry Street Site in Waterbury, Connecticut, hereafter referred to as the "Site." This Radiation Protection Plan (RPP) is a companion document/appendix to H&A's Site Health and Safety Plan (HASP), and as such certain descriptive information contained in the HASP may not be repeated.

The purpose of this RPP is to establish radiation protection procedures for CABRERA, H&A, contractors, and other personnel involved in site work involving potential exposure to radiological hazards. This document is a working document and is subject to change based on review and the implementation of additional tasks.

This RPP establishes the work practices necessary to help ensure the radiological protection of personnel assigned tasks on the site, the local community, and the environment during site activities. The objective of this RPP is to anticipate, identity, evaluate, and control potential radiological hazards.

Site activities will be performed in accordance with this RPP, the HASP, and other applicable health and safety regulations, CABRERA's Radiation Safety Program (CABRERA, 2010), U.S. Nuclear Regulatory Commission (NRC), Occupational Safety and Health Administration (OSHA), and other applicable local and federal statutes. CABRERA Standard Operating Procedures (SOPs) that are referenced within this RPP are the most current revisions of radiological Administrative Procedures (APs) and Operational Procedures (OPs) from CABRERA's Radiation Safety Program (RSP).

The levels of personal protection and procedures specified in this plan are based on the best information available from reference documents and current site data. Therefore, these recommendations represent the minimum health and safety requirements to be observed by personnel engaged in this project. Unforeseeable site conditions may warrant a reassessment of the recommended protection levels and controls. Revisions to the RPP must have prior approval by the CABRERA Corporate Radiation Safety Officer (RSO), the Project Certified Health Physicist (CHP), or the Project Health Physicist (PHP).

1.2 SITE INFORMATION

The Site is occupied by five abandoned industrial-use buildings. Three of the buildings are contiguous buildings composed of 4 to 6 stories that occupy the majority of the Site: the rectangular-shaped building designated as 39 Cherry Avenue comprises the western border of the Site, and L-shaped buildings designated as 177 Cherry Street and 215 Cherry Street are perpendicular to the eastern border of Cherry Street. A garage building abuts the northern border of 39 Cherry A venue and a former office/carriage house (0 Cherry Street) stands alone on the

Subcontract #38563-000 CABRERA SERVICES INC. 1-1

NOI Waterbury, CT Site Radiation Protection Plan -FINAL Revision 2 (May 2014)

southwestern property border. Basement crawl spaces are present on the northern portion of 39 Cherry A venue and the eastern portion of 177 Cherry Street. The Site is located on a southerly-sloping hill, which complicates the identification of the floors within the three contiguous buildings as they are oriented to each other and to ground elevation. In order to allow for the most consistent identification of levels between buildings, previous investigations identified the floors from the top down, beginning with the 6th floor (which is the top floor contiguous along all three main site buildings) and counting down through the floors. In this manner, the northern portion of the 215 Cherry Street building is identified as Floor 2 at ground level, although this same elevation is two stories high at the southern end of 39 Cherry A venue. With this identification system, no "Floor 1" exists for 215 Cherry Street, located at the highest ground elevation of the Site.

The Site buildings were formerly part of the Waterbury Clock Company complex where, in the early 1900s, portions of the contiguous buildings were used to paint clock dials with !urn inescent paint containing radium. The Connecticut Department of Energy and Environmental Protection (CTDEEP) Radiation Division has been involved with the assessment of the Site and determined that building materials in portions of the contiguous site buildings are contaminated with radium. Remediation of these areas was initiated in 2002 but not completed as activities were ceased when a layer of asbestos material was observed between flooring.

For the purposes of this RPP, the Site is considered to consist of the buildings with addresses of 39 Cherry Avenue (designated as Buildings 1 and 2), 177 Cherry Street (Buildings 6 and 7), and 215 Cherry Street (Buildings 3 and 4). The Site radionuclide of concern (ROC) is radium-226 e26Ra) in the form of legacy watch dials, paint, wastes, artifacts, and distributed contamination on building or equipment surfaces.

Additional Site descriptions and history may be obtained from H&A's project HASP.



2.0 ORGANIZATIONAL STRUCTURE

Radiation Protection Plan - FINAL Revision 2 (May 2014)

Key H&A project personnel responsibilities and contact information are provided in the project HASP. Key CABRERA project personnel are as follows with contact information presented in Table 2-1:

• Program Manager - The Program Manager (Rob Flowers) is responsible for overall project objectives, scope, budget, and quality of submittals, ensuring that adequate corporate resources are made available to the PM, and providing senior review and support.

• Project Manager (PM) - The PM (Chris Wright) is responsible for planning, coordinating, integrating, monitoring, and managing project activities. He is also responsible for day-to-day management and monitoring of the project budget, schedule, and scope. He will be the contractor's primary point of contact with H&A and the regulatory team members. He will work directly with the Site Radiation Safety Lead during implementation of on-site activities.

• Corporate Radiation Safety Officer (RSO) - The RSO (Mike Winters, CHP) is responsible for oversight of all Cabrera radiological activities and implementation of, and adherence to, Cabrera's RSP. He is the RSO for, and responsible for all activities associated with, Cabrera's NRC radioactive Materials License (Cabrera, 20 13a). The RSO has the authority to direct activities, stop work (and restart based on consultation with the PM) and to take appropriate actions, as required, to address radiological emergency situations.

• Project Certified Health Physicist (CHP) - The Project CHP (Henry Siegrist, CHP, PE [Professional Engineer]) is responsible for the quality of radiological field activities and has authority to direct such activities, and to take appropriate actions, as required, to address radiological emergency situations. He will work directly with the Project Health Physicist to provide assistance and direction to ensure that radiological activities, controls, and procedures are properly implemented and followed.

• Project Health Physicist (PHP) - The PHP (Roy Racino, RRPT [Registered Radiation Protection Technologist]) is responsible for the quality of radiological field activities and has authority to direct such activities, and to take appropriate actions, as required, to address radiological emergency situations. He will work directly with the PM and field personnel to ensure that radiological activities and procedures are properly implemented and followed.

• Site Radiation Safety Lead (SRSL)- The SRSL (Michael Plonski, RRPT) is responsible for the implementation of field activities. He will be in frequent communication with the PM and PHP and will be the on-site point of contact for other project team personnel. He will be responsible for the daily radiological field activities of CABRERA staff and subcontractors. He is responsible for preparation and submittal of field quality control submittals and will work with other team members with quality assurance (QA) responsibility to ensure that field activities are completed in a safe and efficient manner, in accordance with radiological protocols outlined herein.



• Health Physics Technicians - Field health physics technicians report to the SRSL and are responsible for conducting field activities in accordance with protocols outlined herein.

Additional engineering and technical support staff may also be utilized to conduct field and offsite efforts.

TABLE 2-1: CABRERA KEY PROJECT PERSONNEL

••·.···~~~~~~'r ,z .. i~%~,--;~':f\fl~~ . ·. / ~:~.,.;~· ~-~~- ·. .. ;'~~\~~~~#\~ {~ ~~1' : . .. .. . .· .. · (:~f~~lit~r ... , .... .

Program Manager Rob Flowers (804) 833-7948

Project Manager Chris Wright (860) 919-1691

Corporate Radiation Safety Officer Mike Winters (352) 610-2150

Occupational H&S Manager Sean Liddy (443) 553-1403

Project Certified Health Physicist Hank Siegrist (860) 416-0196

Project Health Physicist Roy Racino (845) 987-6987

SRSL Michael Plonski (860) 794-6915

Health Physics Technicians Jon Cote (860) 305-0048

Nick Berliner (860) 916-6091



3.0 HAZARD ASSESSMENT


Radiological hazards and appropriate hazard controls and protective measures will be assessed prior to the start of work in radiological areas and specified in Radiation Work Permits (R WPs ). The hazards assessment will consider the level of contamination, potential exposure to radiation, the environment in the work area, and the type of work being performed. Industrial and chemical hazards are addressed in H&A's project HASP. The SRSL and the H&A Site Safety Officer (SSO) will assure personnel protective measures address both radiological and nonradiological hazards. The SRSL, with concurrence and approval from the PHP, Project CHP, or RSO, will make final determination of radiological controls on the RWPs prior to the start of each task identified below. The SSO will provide input and concurrence for common radiological and safety concerns such as respirator and fit test requirements.

3.I TASKS TO BE PERFORMED

Task 1 - Site Investigations: This task consists of mobilizing personnel and equipment to the NOI property, setting up office and radiological instrument counting and quality control areas, conducting project-specific training for site workers, establishing appropriate building access/egress points, scoping surveys and establishing radiological boundaries to maintain radiation protection controls.

For the purposes of this RPP, it is anticipated that Task I activities will consist of non-toslightly intrusive activities such as building walk-throughs and inspections, building structural evaluations, and associated radiation protection support within areas defined as the Site in Section 1.2 ofthis RPP.

Task 2 - Asbestos Containing Material (ACM) Debris Abatement/Radiological Screening Activities: This task pertains to abatement, material sizing/ waste reduction and material handling. In addition this task will cover the radium screening process.

3.2 TASK 2 ACTIVITIES

The purpose of the radium radiological screening process is to support ACM abatement work to clear out residual debris and materials from floors of buildings on the Site. The screening will determine if wastes that are generated will be disposed as ACM wastes only or require disposal as radium-contaminated ACM. Radiological support will include several activities.

Prior to asbestos abatement activities, a Cabrera health physics technician (HP Technician) escorted by an asbestos trained individual will pre-screen the debris piles for the presence of radium using a live-time dose rate instrument (Ludlum Model 2221 ratemeter/scaler with a Ludlum Model 44-20 3-inch by 3-inch sodium iodide [3x3 Nai] probe, or equivalent). Fifty (50) direct total contamination (static) measurements will be taken on each floor within the contracted area at random locations determined by Cabrera HPT' s. In addition static measurements will be taken on oversized and selected debris items using a Ludlum Model 2224 ratemeter/scaler with a Ludlum Model 43-93 alpha-beta scintillation probe, or equivalent.

The HP Tech will radiologically screen packaged waste debris at a sampling frequency of not less than I 0 percent utilizing the Cabrera Large Area Scanning System (CLASS). The screening



will be performed on discrete packages with the detection unit in a fixed/reproducible position to ensure optimization of data collected for material screened. Bags of wastes will be scanned at a rate of approximately 3-inches per second with the detector approximately 6-inches from the exterior surface of the bag. Calculations and assumptions for parameters such as bag diameters, total weight of wastes in the bags, detector type and distances, and countrate or doserate conversions to Ra-226 activity in the bags are provided in Attachment 2 of this RPP. Elevated levels of material will have an isotopic analysis to ensure accurate information for waste characterization labeling of such waste and for transportation and disposal. Should radium be detected above the project release limit of 3x the established background (200% BKGD [naturally observed background] plus BKGD), screening will be performed more frequently until the radium activity diminishes to project acceptable levels. Items that are too large to be released using the CLASS will be released in accordance with Regulatory Guide 1.86 referenced in section 7.3.4.1 table 7-3 of this RPP. The previously described radiological screening sample rate of 10 percent will also apply to these large items.

Radium activity that is detected in debris, including wastes generated by these activities such as air handling unit filters and other investigation derived wastes, that is above the project acceptable level will be separated from the non-radium contaminated debris. Radium contaminated debris will be staged in a designated radioactive materials area for later disposal at an approved facility.

Radiological protection support will be provided throughout the ACM abatement activities as described in this RPP.

3.3 HAZARD COMMUNICATION

The project HASP discusses the overall methods used to comply with the Occupational Safety and Health Administration (OSHA) Hazard Communication Standard 29 Code of Federal Regulations (CFR) 1910.1200 (OSHA, 2004). See Section 4.0 of this RPP for addressing radiological hazard communication.

3.4 RADIOLOGICAL HAZARDS

Radiological information and properties of the Site ROC 226Ra are presented in Table 3-1. Monitoring will be performed to determine radiation levels and radionuclide concentrations on surfaces and to verify radiological controls are sufficiently protective of Site personnel, the public and environment.

radium-226

1 a = alpha; y =gamma;


TABLE 3-1: NOI SITE ROC

CABRERA SERVICES INC.

a- 4.78 MeV (93.84%) -0.186MeV

3-2


4.0 TRAINING AND RECORDS


Reference H&A's project HASP for training requirements for this project and the use of daily tailgate safety meetings and required information for recordkeeping. Radiological safety will be included as part of the daily safety meetings. In addition to the required information in the HASP, each Cabrera employee involved in field activities is required to provide evidence of radiation safety training attendance within the past 12 months. This training shall be in conformance with CABRERA SOP AP-009, Training (CABRERA "radiation worker" training) and will include topics required by NRC Title 10 Code of Federal Regulations, Part 19 (1 0 CFR 19), and Part 20 (I 0 CFR 20) (NRC, 2004). These topics include:

• Familiarity with this RPP and other project-specific procedures for the identification of radiological hazards and controls necessary to maintain personnel, environment and public exposure to radiological hazards at the Site as low as reasonably achievable (ALARA);

• Radioactive material present or suspected of being present at the Site, including type, form, and radionuclide content;

• Health and safety hazards associated with the radioactive material and radionuclides present at the Site and potential exposure pathways;

• Site-specific procedures specific to activities anticipated;

• Specific radiological controls applicable to the Site, project activities, and radiological hazards present;

• Worker responsibility to report unsafe acts or procedures which might result m unnecessary exposure to radiation or radioactive material;

• Worker response to on-site events and occurrences with radioactive material; and

• Worker's rights and responsibilities with respect to working with radioactive material.

Site workers that are performing non-asbestos removal activities such as walk-throughs, general inspections, or building structural assessments, will not require the preceding CABRERA AP-009, radiation worker training. At a minimum, personnel entering impacted areas will require CABRERA project-specific Radiation Awareness Safety Training. This awareness training ensures compliance with the OSHA Hazard Communication Standard requirement for evaluating and communicating potential health hazards due to the elements and chemicals present at a site, specifically radioactive materials for the NOI Site. Personnel only having Radiation Awareness Safety Training will require 100% health physics oversight when conducting activities in areas defined as the Site in Section 1.2 of this RPP.

Hazard communication for non-radiological hazards that have been identified or may be encountered at the NOI Site will be addressed by H&A's project HASP.

Site employees who may be required to use respiratory protection shall provide the following records:

• Medical approval for use of respiratory protection, including a statement from the examining physician or physician's representative indicating the recommended re-



examination frequency if not every 12 months (in lieu of this statement the frequency is assumed to be every 12 months);

• Evidence of respiratory protection training completion within the previous 12 months; and

• Qualitative fit testing will be performed prior to respirator use via a challenge with irritant smoke or saccharine with the type manufacturer, model and size of respiratory protection device to be used at the Site. Note: If other than tight fitting face piece respiratory protection devices are required, e.g., loose fitting hood, etc. fit test records are not necessary.

Employee records discussed in this section, as well as exposure monitoring results collected during performance of Site tasks shall be secured from unauthorized access. Access to employee records shall be limited to radiation protection staff responsible for records maintenance, the project RSO, SRSL, the employee, and individuals designated by the employee. Federal and/or State employees with a need to access, such as in the performance of inspections or assessments, shall be granted access to all project records as necessary to facilitate performance of their assigned task.



5.0 ACTIVITYHAZARDANALYSIS

Radiation Protection Plan -- FINAL Revision 2 (May 2014)

The radiological activity hazard analysis is an ongoing process from the initiation of the RPP preparation through the implementation and completion of the project. The minimum sitespecific radiological hazards associated with the activities associated with each task and the proposed control measures are provided in the Activity Hazard Analyses, Attachment 1 to this RPP. Additional controls will be implemented if surveys indicate actual radiological conditions are different than expected. For Task 1 activities within the impacted buildings, the definition of slightly intrusive activities will encompass moving materials or containers slightly in order to visually observe hidden structural surfaces or container markings/labels, probing structural surfaces with a sharp object to determine material integrity, or touching surfaces to determine surface condition, composition, or integrity. Whenever possible, HP personnel will perform slightly intrusive activities for investigation personnel (non-radiation worker trained). If it's necessary for non-radiation worker trained personnel to handle or touch legacy surfaces, they will do so with oversight and surveillance by HP personnel.

General equipment, inspection, and training requirements are identified in Attachment 1. Inspection and training requirements are included by reference from the CABRERA Occupational Health and Safety Management System (OHSMS) (CABRERA, 2013). Health and safety equipment, such as monitoring instruments and personal protective equipment (PPE), are specified in the Activity Hazard Analysis (AHA) for the task. PPE for radiological is also addressed in this RPP. The CABRERA SOPs referenced in this RPP will be maintained in the radiation protection field offices. Requirements will be revised if actual/additional measurement equipment used is different than expected.



6.0 SITE CONTROL


Radiological areas will be identified and controlled as discussed in the following sections. Site preparation and project task performance shall be conducted in accordance with RWPs prepared and approved in accordance with CABRERA SOP, AP-012 Radiation Work Permits.

6.1 GENERAL SITE ACCESS

General site access is discussed in H&A's project HASP.

6.2 RADIOLOGICAL CONTROL AREAS

Radiological control areas (RCAs) are designed to prevent employees, contractors, visitors, and the surrounding environment from undue risks from exposure to radiation and radioactive materials during site activities. RCAs at the Site may consist of a Radiation Area (RA), Airborne Radioactivity Area (ARA), Contamination Zone (CZ) and Contamination Reduction Zone (CRZ), also referred to as a Buffer Zone. A RCA will be established to encompass any area where intrusive tasks are being performed, as well as areas where radioactive material is or may be present, stored, or handled. If tasks are being performed concurrently at separate areas of the Site, several RCAs may be established to support the work. Movement of personnel and equipment between work areas and on and off the site will be controlled by means of designated access points. The radiological hazards and hazard controls, including required PPE, will be specified in the applicable RWP for work in RCAs.

Entries into the buildings will be considered as entries into potentially contaminated areas that require 100% health physics oversight for non-radiation worker trained personnel. For Task 2, additional localized RCA's will be established to support work activities.

6.2.1 Radiation Area (RA)

A RA will be designated as any personnel accessible area in which there exists ionizing radiation such that an individual could receive a deep dose equivalent (DDE) in excess of 5 millirem in 1 hour (mrem/hr) at 30 centimeters (em) from the radiation source, or from any surface that the radiation penetrates. All RAs shall be delineated with sufficient indicators, such as barrier rope or ribbon, to identity the boundary of the RA and properly posted.

RAs are not anticipated on the Site with the exception of potential localized areas in the form of concentrations of watch dials, radium paints, or wastes.

6.2.2 Airborne Radioactivity Area (ARA)

An ARA means a room, enclosure, or an area in which airborne radioactive materials, composed wholly or partly of licensed material, exist in concentrations in excess of the derived air concentration (DAC), in units of microcuries per milliliter ().lCi/mL ), as specified in 10 CFR Part 20, Appendix B, Table 1, Column 3 (NRC, 2004), or to such a degree than an individual present in the area without respiratory protective equipment could exceed, during the hours an individual



is present in a week, an intake of 0.6 percent of the Annual Limit on Intake (ALI) or 12 DAChours. Section 7.3.5 of this RPP presents air monitoring limits for 226Ra.

6.2.3 Contamination Zone (CZ)

A CZ will be designated and delineated for areas that have the possibility of exposing Site employees or the surrounding environment to contamination and/or contaminated material. As such, they may be considered potentially contaminated areas. Potential CZs for this project are:

• Portions of the Site designated as impacted per previous radiological investigations.

• Portions of the buildings that have not been adequately characterized for residual radioactive materials.

• Smear handling and counting area(s).

6.2.4 Contamination Reduction Zone (CRZ)

A CRZ will be established between the CZ and any non-contaminated area. Personnel and equipment that exit a CZ will do so through the CRZ.

Equipment and initial vehicle decontamination may be perfonned in a CZ. However, personnel and final equipment decontamination shall be located in the CRZ. The CRZ will contain the equipment necessary for personnel decontamination and decontamination verification, and may be equipped with designated "step-off areas" for personnel following doffing of potentially contaminated PPE.

For Task 1 activities, building access/egress points will serve as CRZs. Task 2 CRZ's will be established just outside of the ACM/CZ containment and have a dedicated control point for egress.

6.2.5 RCA Entry and Exit

When exiting a CZ, personnel and equipment must pass through the CRZ. Potentially contaminated PPE will be removed in the CRZ and placed in waste containers. Personnel decontamination shall be performed prior to exiting the CRZ if contamination is detected above background. Each CRZ will have waste containers provided (drums, etc.) where doffed PPE will be disposed.

No eating, drinking, chewing, or smoking shall occur in a RCA, CZ or CRZ. Tobacco products, food, gum, or drinks will not be taken into any of these zones

6.3 SUPPORT ZONES

Support Zones (SZ) are uncontrolled 'clean' areas at the Site. SZs encompass both the overall support infrastructure (i.e., site trailers, vehicles, personal hygiene and sanitary facilities) as well as smaller, task-specific SZs that may be established adjacent to CRZs. These SZs may consist of offices, break areas, equipment and PPE staging areas, and engineering control support centers. PPE will not normally be required in a SZ.



If personnel are performing work in PPE in a CZ, a minimum of one person will be in the SZ at all times. This person will have access to communications with the SRSL and SSO (e.g., cellular phone or two-way radio).



7.0 RADIATION SAFETY PROGRAM

The CABRERA RSP will be implemented to protect worker's health and safety during Site activities. The SRSL ensures that contamination control activities are effective, samples and areas are not cross-contaminated, occupational doses are maintained as low as reasonably achievable (ALARA) in accordance with CABRERA SOP AP-005, ALARA, workers and the environment are protected, and that activities comply with radiological procedures in the RSP. Methods and programs used to protect the workers, site visitors, the public and the environment are discussed in the following sections.

7.1 ALARA

The ALARA principle is to maintain personnel exposures to ionizing radiation as low as is reasonably achievable, consistent with the purpose for which the activity is undertaken, and taking into account technologies and the economics of improvements in relation to benefits to the public health and safety and other societal and socioeconomic considerations. The NRC and project annual occupational individual exposure limits are presented in Table 7-1.

TABLE 7-1: SITE EXPOSURE LIMITS AND ALARA EXPOSURE GOALS

NRC Annual Project Annual Occupational Exposure Limit

Exposure Limit (rem) (rem)

Total Effective Dose Equivalent (TEDE) which is the sum of the Deep Dose Equivalent (DDE)1

5.0 0.025 and Committed Effective Dose Equivalent (CEDE)

Sum of the DDE and Committed Dose Equivalent (CDE) To Any Organ or Tissue 50 0.75 Other than the Lens of the Eye

Lens of the Eye (Lens Dose Equivalent or LDE) 15 0.15

Skin of the Whole Body2 or Extremities3

50 0.5 (Shallow Dose Equivalent or SDE4)

. . The asstgned DOE must be for the part of the body recetvmg the htghest exposure . Whole body is defined as the head, trunk (including male gonads), arms above the elbow and legs above the knee. Extremity is defined as the hand, elbow and arm below the elbow; foot, knee and leg below the knee.

4 The assigned SDE must be the exposure averaged over the contiguous I 0 square centimeters of skin receiving the highest exposure.

In addition to individual exposure goals in Table 7-1, an administrative collective dose goal of 0.1 person-rem TEDE will be implemented for Site work activities.

Although the project exposure limits in Table 7-1 are well below limits that would permit their exposure to ionizing radiation at the Site, CABRERA's radiation safety policy does not allow minors (under the age of 18) or declared pregnant women access into known airborne or contamination areas. Management, planning and performance of work at the Site will be such


NOI Waterbury, CT Site Radiation Protection Plan·- FINAL Revision 2 (May 2014)

that the project annual exposure limit is not exceeded. Adherence to the project limit will be accomplished through radiological support surveys and individual internal exposure monitoring.

Formal ALARA pre-job reviews will be conducted for tasks that include any of the criteria listed in Table 7-2 or as determined necessary by the RSO and per levels of associated risk factors presented in AP-005. The purpose of the ALARA pre-job review is to assure the proposed tasks are evaluated and methods to maintain occupational exposure ALARA are evaluated and required controls specified. The results of the ALARA pre-job review are typically incorporated into the applicable RWP(s) for the task.

TABLE 7-2: ALARA FORMAL JOB REVIEW REQUIREMENTS

Work Conditions (CABRERA SOP AP-005)

1. An individual dose is expected to exceed 25 millirem (mrem)

2. The collective dose for the job/task exceeds 0.1 person-rem.

3. Airborne exposures exceed 12 DAC-hours per week for any single individual.

4. General area dose rates exceed 1 mrem/hour.

5. Contamination levels exceed 100 times the values in RPP Table 7-3, Section 7.3.4.1.

6. Use of supplemental engineering controls (air filter systems, glove bags, tents, and other similar devices) and respiratory protection to reduce potential internal exposures.

7. Installation, removal, or modification or temporary shielding.

ALARA pre-job reviews are not planned for the scope and anticipated radiological conditions for Site work activities. Direct HP oversight will ensure non-radiation worker trained workers do not work/remain in areas where Table 7-2 conditions may exist.

7.1.1 ALARA Tracking

ALARA in-progress reviews will be performed periodically as the task proceeds and will continue until the task has been completed or the ALARA pre-job review and associated RWP(s) revised, if necessary. Periodic ALARA in-progress reports will be submitted no less frequently than each calendar quarter when work is performed, to the CABRERA PM as well as designated CABRERA senior HP staff for review. These reports will serve as the primary means for ALARA-based work plan changes or revisions.

Following completion of each task that required an ALARA pre-job review, the actual occupational exposure received will be compared to the exposure estimate. The ALARA postjob reviews will be performed in accordance with AP-005 and will evaluate the inputs to the prejob review, such as the overall task performed, estimated and actual person-hours for task performance, administrative and engineering controls, changes in work plan or work



performance, etc., to determine the cause of the deviation and identifY lessons-learned, as necessary, to further improve the execution of the RSP.

7.1.2 Contamination Containment

Containment enclosures are utilized for intrusive tasks to contain and minimize the potential for the spread of surface contamination and airborne radioactivity within and outside the work area. If utilized, containment enclosures will be constructed, maintained, and operated in accordance with CABRERA SOP OP-014 Contamination Containment Devices. For Task 2 activities, ACM containment enclosures will be required (Refer to the HASP for ACM abatement containments) and will also serve as radiological containment.

7.1.3 Local Ventilation

Engineered systems to assist in the containment and control of airborne radioactive materials, chemical contaminants, and ACM will include the use of localized exhaust ventilation with a combination of roughing and high-efficiency particulate air filters. Implementation includes proper sizing/capacity of the system(s) and ensuring proper air flow through a work area.

In conjunction with the ventilation system(s), continuous air sampling is performed to verify adequate work area ventilation for worker occupancy and to monitor exhaust air radionuclide effluents to not exceed annual air effluent discharge limits to the general public.

7.2 RADIATION WORK PERMITS

RWPs serve as tools in identifYing radiological hazards for project tasks to be performed and specifYing hazard mitigation and control measures necessary to protect workers from the radiological hazards, including PPE required for the task(s). RWPs will be generated in accordance with CABRERA SOP AP-012 Radiation Work Permits. PPE selection and specification in the RWPs will be in accordance with CABRERA SOP AP-010 Personal Protective Equipment.

7.3 RADIATION SURVEYS AND MONITORING

7.3.1 Survey Methods

Radiation and contamination surveys will be perforn1ed in accordance with CABRERA SOP OP-00 1, Radiological Survey and using the most current CABRERA standard excel template "Alpha Beta Counting and Smear Worksheet".

7.3.2 Survey Documentation

Completed, original paper copies of survey records, R WPs, field data, field records, analytical data, training records, and other project-specific documentation will be retained in a secured location at the NOI Site in accordance with CABRERA SOP AP-00 I, Rev. 0, Record Retention.

7.3.3 Radiation Surveys



Radiation surveys include dose or exposure rate measurements and will be performed throughout portions of the Site as they are accessed/traversed to perform Task 1 activities and Task 2 preabatement survey activities and as determined necessary by the SRSL or specified on the applicable RWP. Dose/exposure rate surveys will typically include general area type (1 meter distance) as well as surface contact. Radiation surveys are also required on external surfaces of packages and/or conveyances prepared for transport in accordance with U.S. Department of Transportation (DOT) regulations and/or International Air Transport Administration (lATA) requirements.

Incoming (receipt) radiation surveys will be performed on items or equipment containing suspect or potentially contaminated surfaces. Radioactive sources utilized for instrument quality control (QC) and operational checks will have incoming radiation surveys performed in accordance with CABRERA SOPs OP-009, Use and Control of Radioactive Sources, and OP-011, Procurement and Receipt of Radioactive Material.

7.3.4 Contamination Surveys

Contamination surveys include direct and scanning measurements for total (fixed plus removable) and removable (loose) activity will be performed and include:

• Area and CZ boundary contamination surveys, equipment and material pre and post decontamination surveys, as well as contamination surveys necessary to support movement of equipment and material from one RCA to another, shall include smears for detection of removable contamination. Large area swipes may be performed over part or all of the surface area of interest and the swipe analyzed using field screening methods for qualitative detection of removable surface activity. Smears may be analyzed using a smear counter or portable field survey instrument with appropriate operational and QC setup to provide quantifiable results.

• Contamination surveys on equipment and material that will be released from the Site shall include direct measurements for total radioactivity and smear samples for removable surface contamination.

• Contamination surveys on packages and/or conveyances prepared for transport in accordance with DOT regulations shall include smears for removable surface activity. Removable surface activity may be averaged over an area not to exceed 300 square centimeters ( cm2

). Smears for compliance with DOT and lATA regulations shall be analyzed using a stationary smear counting system with appropriate scaler (such as a Ludlum Model 2929 coupled with an alpha/beta scintillation detector or equivalent), or portable field survey instrument with appropriate operational and QC setup to provide quantifiable results.

• Radioactive sources utilized for instrument QC and operational checks will have incoming contamination surveys ((leak tests) performed in accordance with CABRERA SOPs OP-009, Use and Control of Radioactive Sources, and OP-011, Procurement and Receipt of Radioactive material.

• Contamination surveys shall be performed on the external surfaces of packages received at the Site containing radioactive material (used for instrument calibration and routine QC checks of instruments), unless the package contains radioactive material in the form of a



gas, NRC-exempt, or sealed sources. Contamination surveys shall also be performed on all packages known to contain radioactive material arriving at the Site, regardless of quantity, labeling or form that have been or appear to have been damaged during transport resulting in package degradation.

• Surveys will be performed on building surfaces throughout portions of the Site as they are accessed/traversed to perform Task 1 activities and as determined necessary by the SRSL or specified on the applicable RWP.

• Personnel contamination surveys will be performed using hand-held instruments (frisking) or through the use of automated personnel monitors.

Large area swipes may be collected for faster, qualitative results. However, smear samples for quantification of removable surface activity will be collected over a finite surface area, ideally 100 cm2, and analyzed using on-site laboratory counting equipment, or portable field survey instrument with appropriate operational and QC setup to provide quantifiable results, for alpha and beta radioactive contamination as per CABRERA SOP, OP-004 Unconditional Release of Materials from Radiological Control Areas.

Routine contamination surveys will be performed to determine the effectiveness of contamination control measures and to assure that materials, working surfaces and equipment are not contaminated with radioactive material. The SRSL will identity areas subject to routine surface contamination surveys. These may include, but are not limited to:

• Support Zone surfaces such as counting laboratory floors and countertops, office and break area floors, desktops, and tabletops.

• Interior surfaces of equipment and truck cabs (floor board, seats, steering wheel, etc.) used within a CZ or CRZ.

• Personnel and equipment travel surfaces outside of a CZ, CZ boundaries (if a solid surface), and "step off areas."

7.3.4.1 Acceptable Surface Contamination Levels

Areas, Equipment and Material

The NRC's Regulatory Guide 1.86 (NRC, 1974) and Policy and Guidance Directive FC 83-23 (NRC, 1983) present industry standards for acceptable surface contamination levels for release for unrestricted use of facilities, equipment, and materials. These limits are presented in Table 7-3 and will be applied to Site equipment and material release, establishing and maintaining CZ's, as well as movement of equipment and material between RCA's. Based on 226Ra, the most conservative removable/average/maximum alpha emitting limits of 201100/300 disintegrations per minute per 100 square centimeters (dpm/1 00 cm2

) will apply. These limits are consistent with the Release Limits for Gross Activity (Unknown Isotopes) presented in CABRERA SOP, OP-004 Unconditional Release of Materials from Radiological Control Areas.



TABLE 7-3: SURFACE CONTAMINATION LIMITS

U-nat, U-235, U-238 and associated decay products

Transuranics, Ra-226, Ra-228, Th-230, Th-228, Pa-231, Ac-227, 1-125, 1-129

Th-nat, Th-232, Sr-90, Ra-223, Ra-224, U-232, 1-126, 1-131, 1-133

Beta-gamma emitters (nuclides with decay modes other than alpha emission or spontaneous fission) except Sr-90 and others noted.

5,000 a

100

1000

5,000 ~-y

15,000 a 1,000 a

300 20

3,000 200

15,000 ~-y 1,000 ~-y

Where surface contamination by both alpha and beta-gamma emitting nuclides exists, the limits established for alpha and beta-gamma emitting nuclides should apply independently.

As used in this table, dpm (disintegrations per minute) means the rate of emission by radioactive material as determined by correcting the counts per minute observed by an appropriate detector for background, efficiency, and geometric factors associated with the instrumentation.

Measurements of average contaminant should not be averaged over more than I square meter. For objects of less surface area, the average should be derived for each object.

The maximum contamination level applies to an area of not more than 100 cm2.

The amount of removable radioactive material per I 00 cm2 of surface area should be determined by wiping that area with dry filter or soft absorbent paper (swipe), applying moderate pressure, and assessing the amount of radioactive material on the swipe with an appropriate instrument of known efficiency. When removable contamination on objects ofless surface area is determined, the pertinent levels should be reduced proportionately and the entire surface should be swiped.

Shipment and Receipt a( Radioactive Material

Removable surface activity on packages and/or conveyances of radioactive material prepared for transport in accordance with DOT regulations shall not exceed the limits in 49 CFR 173.443 and lATA, as applicable. The SRSL may impose lower limits as an added control measure.

The SRSL shall be notified immediately of incoming packages containing radioactive material with detectable removable surface contamination. The SRSL shall determine the appropriate actions to be taken based on the results of the contamination survey, the type and quantity of radioactive material, and the condition of the shipping package.

Only DOT (and lATA if hazardous material transport by air) trained individuals may package and ship hazardous materials. This includes shipments of NRC licensed sources as well as certain NRC exempt check sources. The SRSL will ensure personnel performing this function have up-to-date training.



Personnel

Radiation Protection Plan- FINAL Revision 2 (May 2014)

Personnel with contamination on skin or hair greater than limits provided in OP-043, Personnel Frisking and Decontamination shall be decontaminated under the direction of the SRSL. The SRSL shall be notified immediately when personnel monitoring indicates detectable contamination in, or in the immediate vicinity of, the mouth, nose or eyes.

7.3.5 Air Monitoring

Radiological airborne monitoring typically will include use of the following:

• Lapel/breathing zone (BZ) air samplers for individual personnel exposure monitoring. • Low volume or high volume grab air samplers (general area air samplers) for area

monitoring in work areas and building/work area effluent air monitoring.

Radiological airborne hazards may be encountered as intrusive activities are performed within an area containing residual radioactive materials. Therefore, air sampling to assess occupational exposure is performed in these work areas to include BZ, low volume, and/or high volume general area air sampling with requirements specified on applicable RWPs.

General area airborne monitoring is conducted utilizing air samplers with flow rates sufficient to provide total sample volumes that will satisfY instrument detection requirements. Lapel, or BZ, air samplers may also be worn by workers performing intrusive work. For work groups performing similar tasks in the same areas, a BZ air sampler may be assigned to a single individual with the highest potential for exposure to airborne radioactivity.

Effluent-specific monitoring will not be performed for ACM abatement activities. Effluent air radionuclide concentrations will be determined using results of general area air monitoring from within the work containment and applying a factor for activity reduction through the HighEfficiency Particulate Air (HEPA) filters that will be employed for containment ventilation prior to exhausting to the main building.

The filters from the air samplers are exchanged after sufficient sample volume has been collected to allow determination of a Minimum Detectable Concentration (MDC) of not greater than 10% of the 10 CFR Part 20 Appendix B (NRC, 2004)for occupational derived air concentrations (DAC) and air effluent limits. The filters may be allowed to decay prior to counting to account for biased results due to radon.

The BZ air sample filters are exchanged after each work shift, provided that a minimum of 8 hours of run time has elapsed (minimum run time is intended to ensure that required minimum detectable activities are met). If Jess than 8 hours was collected during a shift, the same filter may continue to be used during the next work shift.

Air samplers shall be calibrated annually or fitted with an airflow measuring device that 1s calibrated annually.


NOI Waterbury, CT Site Radiation Protection Plan ·- FINAL Revision 2 (May 2014)

Air sample filters are counted using a dual-channel Ludlum Model 2929 alpha/beta scaler coupled to a Ludlum 43-10-1 scintillation detector, or equivalent system. Airborne survey detection capability and MDCs will be based upon 10% ofthe specific limits, or:

• DAC for 226Ra of 3E·10 J.lCi/mL (Class W) =MDC of 3E. 11 J.lCi/mL.

• Effluent limit for 226Ra of9K13 f.lCi/mL =MDC of9E-14 f.lCi/mL.

Initial worker inhalation intakes are evaluated using work area and/or BZ air sample results compared to the DAC. The PHP or Project CHP will determine further sampling and analysis requirements based on evaluation of the laboratory analysis results. CABRERA SOP OP-002, Air Sampling and Analysis, provides the instructions regarding collection and decay of air samples. The most current CABRERA standard excel template "BZ and Effluent Air Samples" is used to calculate airborne concentrations.

Alpha airborne concentrations are based on the following equation:

A . C . (JiCi) a(dpm)*l.3 zr oneentratwn --3

= -------"---------em dpm 3

(2.22£6 JiCi )(Sample Volume, em )

The alpha airborne concentration equation is a simplification of the general air sampling equation:

where:

Ar= filter activity in dpm; cm3 = cubic centimeters ~:> = collection efficiency; e =natural logarithm base "e" f = flow rate of sampler; A = decay constant of target nuclide; ts = sampling time; tct = delay time (between when the sample collected and the sample is counted)

For long-lived nuclides, the decay terms can be ignored. The 1.3 represents an alpha selfabsorption correction factor due to impaction/burial of alpha emitting material on the filter. (National Council on Radiation Protection [NCRP], 1985)

If air sampling indicates an employee exposure to 30% (0.3) of the applicable DAC, the area will be posted as an airborne radioactivity area. DAC-hour tracking will be initiated for Site workers who will spend 40 hours in an ARA or have the potential to exceed 10% of the ALI based on air sampling results. Airborne concentrations at 30% DAC will lead to exposures of 12 DAC-hours in one week. Affected employees' exposure shall be recorded and included in the individuals' exposure history record.



7.3.6 Radiological Survey Instruments

Radiation Protection Plan-- FINAL Revision 2 (May 2014)

The following examples of instruments (or their equivalent) will be used to support work activities:

• Bicron Microrem/Ludlum Model 19 for performance of area and material gamma dose/exposure rate measurements.

• Ludlum Model 3 coupled to a Ludlum Model 44-9 Geiger-Mueller detector for frisking/scanning personnel, surfaces, and materials for contamination.

• Ludlum Model 2224-1 ratemeter coupled to a detector capable of measuring alpha and beta radiation, such as the Ludlum Model 43-93 scintillation detector for direct surface alpha-beta activity contamination measurements and field screening/quantitative counting of smears.

• The Ludlum Model 2929 alpha/beta scaler coupled to the Ludlum 43-10-1 scintillation detector for quantitative analysis of smears and air sampling filters.

• The Cabrera Large Area .Scanning .System (CLASS) is a Nal crystal used for low level dose rate surveys along with gamma spectroscopy and isotope identification.

• The Ludlum model 2221 ratemeter coupled with a low energy Ludlum Model 44-20 Nal detector (3x3).

Survey instrument MDCs for contamination monitoring will be verified, prior to use, to be 50% of the applicable limits listed in Table 7-3 as practicable for the specific instrument. In all instances, MDCs will not exceed the limits in Table 7-3. Survey and counting instruments are calibrated annually using radioactive sources traceable to the National Institute of Standards and Technology (NIST) and source checked on a minimum of a daily basis to verify acceptable performance. Source checks are performed in accordance with CABRERA SOP OP-009, Use and Control of Radioactive Check Sources. Adherence to SOPs for other routine on-site daily instrument QC such as verification of calibration date, voltage settings, battery check, and general observation of instrument condition will be required. Calibration and use of the instruments is found in CABRERA SOP OP-020, Operation of Contamination Survey Meters, and SOP OP-021 Alpha-Beta Counting Instrumentation. Class operation is performed in accordance with SOP OP-074 - Cabrera Large Area Scanning System (CLASS) System Setup and Use. Operation of dose rate meter will be used in accordance with OP-023- Operation of micro-R meters.

7.4 PERSONAL RADIOLOGICAL MONITORING

7 .4.1 External Radiation Dosimetry

The potential for external exposure for Site employees working in RCAs and with radioactive material is low based on information concerning residual radioactive materials and contamination known to be present within the Site buildings. Therefore, the potential external dose contribution to a Site employee's exposure is expected to be well below the Project exposure limits in Table 7-1 and project personnel are not required to be issued whole body or extremity radiation dosimetry. General area external dose rates will be verified during Task 2 pre-abatement survey activities.



7.4.2 Internal Exposure Monitoring

Radiation Protection Plan -FINAL Revision 2 (May 2014)

Internal exposure monitoring shall be performed for all Site employees required to use respiratory protection for radiological protection purposes, as well as individuals required to access an ARA, individuals inadvertently exposed to airborne radioactivity, or individuals with potential internal exposure resulting from an injury while working in or on contaminated material and with the potential for exceeding the project exposure limits. The primary means of internal exposure monitoring will be through use of BZ air sampling. General area concentrations based on occupational air sampling and stay times may also be utilized. In addition to BZ air samples, the RSO or SRSL may require in-vivo and/or in-vitro bioassay to assess potential intakes of radioactive material resulting from routine work activities or accidental exposure, typically indicated by elevated air sample results, nasal or facial contamination, or contamination in or near a puncture wound. If in-vivo or in-vitro bioassay is required, the RSO or SRSL shall assure the analytical laboratory meets the performance specifications for indirect bioassay recommended in American National Standards Institute, Inc. (ANSI) N 13.30, "Performance Criteria for Radiobioassay" (ANSI, 1996). The RSO or SRSL shall also assure this laboratory has written procedures that document the laboratory's analytical capabilities for the radionuclides of concern, including detection sensitivities, and a QA/QC program which assures the validity of the analytical results.

Calculation of occupational exposure from internal sources of radiation using bioassay results will be conducted in accordance with the guidance in NRC Regulatory Guide 8.9, "Acceptable Concepts, Models, Equations, and Assumptions for a Bioassay Program" (NRC, 1993).



8.0 LEVELS OF PERSONAL PROTECTIVE EQUIPMENT

All Site personnel shall be required to use the appropriate level of protection. The minimum level of PPE are discussed in the following subsections and presented in Table 8-1. If conditions are identified requiring a change in the level of protection, then PPE will be upgraded or downgraded according to guidelines in this RPP and the change reflected on the applicable RWP prior to continuing work activities. A description of the PPE requirements for the levels specified for use at the Site is provided in the following sections.

8.1 LEVEL D PPE

Level D PPE will be worn during non-intrusive activities where no known contamination is present. Level D PPE consists of the following:

• Work clothes, e.g., coveralls (cotton), or full-length pants and long-sleeve shirt.

• Work gloves, leather or cotton as necessary for physical hazards.

• Boots, certified according to the American National Standards Institute.

• Safety glasses with side shields, as necessary for physical hazards.

• Hard Hats, as necessary for physical hazards.

• Hearing protection (during noise-generating activities).

8.2 MOD/FED LEVEL D PPE

Modified Level D PPE will be employed when conducting activities with known or potential contact with radioactively contaminated materials. In addition to the Level D components listed above, the following items will be added:

• Shoe covers or booties.

• Water resistant gloves (in addition to or replacing leather gloves depending on the work activity to be performed).

• Latex gloves for handling/packaging of samples or used air filters and if investigation activities will involve touching interior building surfaces or handling materials within the buildings. May be used in place of above work gloves as work activity permits.

• Tyvek ™ suits or lab coats.

8.3 LEVEL C PPE

Level C PPE will be employed when conducting activities with radioactively contaminated materials with the potential for airborne contamination. In addition to the Modified Level D components listed above, the following items will be added:

• Full face respirator with P-1 00 or combination particulate/volatile organic compound cartridge.

• Water resistant Tyvek™ suit (standard suit allowable for non-intrusive waste activities).



Level B and A PPE are not discussed and will not be considered under the scope of Task 1 or 2 activities.

Conditions that may warrant changes in PPE may include, but are not limited to elevated airborne contamination that cannot be adequately controlled through engineered systems or encountering potentially hazardous conditions that have not been previously evaluated.

TABLE 8-1: INITIAL SITE PPE REQUIREMENTS

':''', ,' ,', ... ' ' s Actii}j;)t uvel ofBrotectJ(jif ..... , ,,,., ,,:: .

•' .•' ' ' y • ' ,."' ' .. , "' '''""'''•

Site Investigation - activities outside the impacted Level D

buildings

Site Investigation -activities within the impacted buildings, handling/scanning packaged materials outside Modified level D the ACM containment

ACM Abatement/inside ACM containment In accordance with ACM

Abatement Procedures

8.4 DECONTAMINATION PROCEDURES

The types of radiological decontamination to be addressed for this project are:

• Equipment and Materials. To remove contamination from equipment to ensure compliance with release criteria.

• Vehicles. To remove contamination from vehicles to prevent spread of contamination and ensure compliance with release criteria.

• Personnel. To remove contamination from clothing or personnel to prevent personnel exposure to radiation and prevent the spread of contamination.

Non-personnel radiological decontamination shall be performed using the guidance presented in CABRERA SOP, OP-018, Decontamination of Equipment and Tools.

Non-personnel decontamination activities will be limited to non-aggressive (dry or wet hand wiping) of small, hand-held items such as meters, clipboards, and personal affects or small, localized areas oflarger equipment or exteriors of waste packaging. More aggressive methods or gross decon oflarger equipment or vehicles will not be permitted under the scope of Tasks 1 or 2 and will require a revision of this RPP to perform.

8.5 PERSONNEL DECONTAMINATION

Contamination of clothing or personnel shall be addressed in accordance with CABRERA OP-243, Personnel Frisking and Decontamination. The following protocols to address clothing and skin contamination are taken from, and consistent with, OP-243.

Contamination may be removed from personnel clothing by patting the affected area with tape and resurveying to determine if additional decontamination is necessary. If contamination



cannot be removed below applicable levels and ALARA, the clothing will be removed from service for disposal as low-level radioactive waste.

Only HP personnel and qualified medical personnel are permitted to decontaminate personnel with skin contamination. If skin decontamination is necessary:

1. Survey the affected area and record the types and initial levels of contamination.

2. If possible, remove particles of contamination with tape and save the particles for evaluation.

3. Attempt localized washing with warm water and soap ensuring the contamination is not spread to uncontaminated parts of the body. Resurvey the affected area to determine if the contamination has been reduced to levels below the applicable levels and ALARA.

4. If contamination persists, decontamination attempts and resurveys may be repeated multiple times but should stop if these methods are ineffective or skin irritation occurs.

5. If the area cannot be decontaminated sufficiently with soap and water, the area may be covered (e.g., with plastic or by wearing latex gloves) to allow contamination to be removed through perspiration.

6. Contaminated wounds of any kind will be decontaminated under the supervision of CABRERA corporate or project HP staff. Severe wounds will be decontaminated under the supervision of medical personnel.

7. Personnel skin contamination must be reported to the RSO, or CHP designee, to determine if a skin dose assessment must be performed.

8. The results of bodily contamination will be recorded on the Personnel and Clothing Contamination Report attachment in OP-243. At a minimum, the information provided in this report will consist of:

• Employee name, date, time, and SSN with RWP number, project name/number, and supervisor,

• When contamination occurred, description of the cause, where it happened and what specific task was being performed,

• How could contamination have been prevented and proposed corrective actions,

• Survey data - surveyor, instrument information, pre-decontamination, after each decontamination attempt, radionuclide/form, decontamination method(s), whole body results (if applicable),

• A human figure (front and back views) to locate contamination,

• Affected employee's and RSO, or designated CHP, signatures with signature dates, and

• A comments/additional information section.

The information requested in this report must be provided as completely and accurately as possible for evaluation of subsequent actions, personnel dose, and for required documentation. This report shall be maintained in the employee's radiation exposure file.



Medical treatment of injuries shall take precedence over radiological considerations. CABRERA corporate or project HP staff shall provide medical personnel with any necessary radiological support in regards to contamination control and monitoring of the patient and medical staff.

8.6 PERSONNEL CONTAMINATION EVALUATION

The following additional actions shall be taken in response to personnel contamination consistent with OP-243:

1. An internal dose assessment may be required for the contamination levels in Table 8-2.

TABLE 8-2: PERSONNEL CONTAMINATION THRESHOLDS FOR INTERNAL DOSE ASSESSMENT

Face 5,000 1,000

Nose or Mouth 1,000 20

Wound 1,000 20

a. In addition, an internal dose assessment may be required for a combination of any detectable radioactivity on nasal or mouth smears (above background) and:

• Skin or clothing contamination exceeding 1,000 dpm alpha, or 5,000 dpm beta-gamma (total)

2. The RSO or his/her duly authorized individual shall determine if a skin dose assessment is required at skin contamination levels that exceed background by:

• 1,000 dpm alpha (total), or

• 5,000 dpm beta-gamma (total)

Internal dose assessments for levels of contamination lower than the above may be performed at the discretion of the RSO, or designated CHP.

When in-vivo examinations are required as a result of an incident, the RSO shall be immediately notified and the affected personnel shall be transported directly to a whole body counter facility as soon as practicable after the incident. When in-vitro examinations are required as a result of an incident, the RSO shall be immediately notified and the affected personnel shall continue supplying samples until directed to stop.

Personnel contamination incidents involving significant levels of total contamination shall be evaluated by a qualified individual (e.g., the RSO, or designated CHP). This evaluation shall assess the need for immediate medical action when personnel contamination exceeds the thresholds (above background) shown in Table 8-2.



9.0 EMERGENCY RESPONSE


Emergency telephone numbers for CABRERA personnel are provided in Table 2-1 ofthis RPP and the Mobe/Demobe AHA. The project HASP provides this information for other project personnel emergency services, and directions and a map showing the route to the nearest medical facility. Personnel will have these lists and map immediately available at all times when performing field activities on the Site.



10.0 MEDICAL SURVEILLANCE AND TRAINING REQUIREMENTS

Requirements for medical surveillance and worker training in addition to radiological presented in this RPP are presented in H&A's project HASP.



11.0 REFERENCES

ANSI, 1996 American National Standards Institute, Inc. (ANSI); Performance Criteria for Radiobioassay; Nl3.30; 1996

CABRERA, 2013 Cabrera Services, Inc.; Cabrera Services Occupational Health and Safety Management System (OHSMS); 2013

CABRERA, 2010 Cabrera Services, Inc.; Cabrera Radiation Safety Program, Revision 1, May 2010

CABRERA, 2013a Cabrera Services Inc.; NRC Materials License, number 06-30556-01, Amendment No.5; June 14,2013

NCRP, 1985 National Council on Radiation Protection (NCRP), A Handbook of Radioactivity Measurements Procedures, 2d Edition, 1985

NRC, 1974 U.S. Nuclear Regulatory Commission (NRC); Termination of Operating Licenses for Nuclear Reactors; Regulatory Guide 1.86; June 1974

NRC, 1983 U.S. Nuclear Regulatory Commission (NRC); Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source, or Special Nuclear Material; Policy and Guidance Directive FC 83-23; November 1983

NRC, 1993 U.S. Nuclear Regulatory Commission (NRC); Acceptable Concepts, Models, Equations, and Assumptions for a Bioassay Program; Revision I; July 1993

NRC, 2004 U.S. Nuclear Regulatory Commission (NRC); Standards for Protection Against Radiation; I 0 CFR 19, I 0 CFR 20; January 2004

OSHA, 2004 U.S. Occupational Safety and Health Administration (OSHA); 29 CFR 1910.1200




This page intentionally left blank

CABRERA SERVICES INC.


11-2


ATTACHMENT 1

Activity Hazard Analyses



ATTACHMENTS

OP SS1 • Project Planning

Project Location: Cherry Street, Rad Survey Support

Contract Number: 38563-000

Date Prepared: 2/14/2014

Prepared by (Nameffitle): Sean Liddy

Reviewed by: Sean Liddy, CSP

Competent Person (if applicable):

Notes: (Field Notes, Review Comments, etc.) The following outlines minimum requirements per accordance with the approved HASP for the project site. Subcontractors are responsible for performing tasks in accordance with the minimum requirements established for the site and in accordance with their own HS&E policies and procedures. Subcontractors shall review and supplement the AHA with company specific HS&E guidance. Modifications or changes to the AHA should be forwarded to the PM/SSHO and reviewed by all project staff prior to performing the task.

Personal Protective Equioment (PPE):

~ Hard Hat ~ Safety Glasses

~ Leather Glove 0 Safety Goggles

0 Kevlar Glove ~ Safety Toe Boots Other PPE: Level D PPE

0 Ear Muffs

0 EarPlugs

~Traffic Vest

~ Long Pants/Sleeves

0 Coveralls (coated)

0 Flame Resistant Clothing

CABRERA SERVICES

as E, H, M, or L "Hazard" on AHA. Annotate the overall highest RAC at

AHA.

0 Inner Glove

0 Outer Glove

0 Face Shield

0 Fall Protection

0 Cooling Vest

0 Welding PPE

0 Wide Brim Hat

0 Half/Full Face Respirator

0 Cartridge/Filter Type:

Safetv Equipment:

~ First Aid Kit

OAirHom

0 Eyewash Station

0 Trekking Poles

~ Eyewash Bottles

~ Insect Repellent

~ Fire Extinguisher (A-B-C)

0 Wheel Chocks

0 Pop-up Shade

0 Cargo Net

0 Sunscreen ~Drinking Water

0 Stretch First Safety First Other

Monitoring Procedures and Action Levels (Refer to Section 3.0 of SSHP):

0 PID (10.6eV) 0 PID (11.7eV) 0 Multi-Rae (PTD+02, H2S, CO, LEL)

Chemicals of Concern (COC): None.

0 PDR (Respirable Dust) 0 PDM (Total Dust) 0 Radiological Meter 0 Personal Air Pump

Job Pre-trip Planning

Complete Vehicle Inspection

Safety Equipment

Hazards Traffic delays, weather

Unserviceable vehicles

Unsecured driver, passenger, or gear and equipment

Controls -Plan your route, research construction delays, weather impacts

-Inspect vehicle for deficiencies, report and correct prior to use. Complete vehicle inspection log each day prior to use.

-Always use seatbelts while vehicle is in motion, lock doors. Always secure the load with a cargo net or rope. Secure all loose equipment in cab.

Page 1 ofS

Job Backing

Driving

Parking

Backing

Driving larger trucks/vans

Heavy equipment operations adjacent to and on site roadways

Heavy equipment cutting roads or clearing vegetation adjacent to roadways or at locations above roadways.

Hazards Blind spots; unseen objects

Rough road surface (potholes), sleepiness, Blind corners, reduced visibility due to dust, fog, snow, ram.

Mobile devices

Crossing Rail road tracks.

Collision, injury to others, possible grass or brush fire from hot vehicle parts (catalytic converter) in contact with · · Collision with stationary objects, backing into ditch

Blind spots; unseen objects; longer stopping, distance; wider turning radius Collisions with heavy equipment, heavy equipment backing out into roadway from side roads or work areas along the rn<>...Jur<n !C

Falling rocks/debris

Controls -Always use a spotter when backing, check mirrors and over shoulder Back into parking spaces upon arrival, whenever possible. When preparing to move or back vehicles, walk around the vehicle 360 degrees before entering vehicle to identify any new conditions or obstructions. Use a spotter when backing whenever possible. Determine and agree upon hand signals (between spotter and driver) before attempting to back vehicle. Check the rear-view and side mirrors prior to backing (Note: All vehicles, other than automobiles, must have small convex mirrors attached to the side mirrors.) Back slowly in areas of obstructed vision. Anticipate others who may be

out into vour oathwav and -Keep eyes moving, use mirrors, follow posted signs, avoid distractions -Aim high in steering, -Maintain 15 sec eye lead time -Leave yourself an out, maintain cushion around vehicle Get the big picture; -Avoid being boxed in, adjust speed to traffic, focus on driving, -Refrain from emotional discussions/NO CELL PHONE. -When approaching a blind corner slow down to 10 mph at least 250 feet from the corner, proceed around the corner at no greater than 10 mph. -During periods of reduced visibility, reduce speeds, pull over and stop until visibility improves, increase following distance during periods of decreased visibility. - Hand held phone use prohibited. No texting. Car on, phone off. - Stop, look, and listen before crossing railroad tracks. Be aware that multiple tracks may have more than one train using them, and the trains may be traveling in opposite directions. Look for direction from track

-Park away from other cars, set brake, park on level terrain, use wheel chocks and turn wheels if parked on sloped terrain. -Park only in cleared areas or where vegetation beneath vehicle is less than 6 inches tall. -Get out and look around vehicle before backing, use a spotter. -When parking, pull through or back in when possible.

-Driver should be familiar with the vehicle they are driving set sideview mirrors to rreduce blind spots

-Know the increased turning radius of the vehicle vs. a small compact

-Slow speeds when approaching heavy equipment activities along or adjacent to roads. -Stop and make contact with operator or spotter to ensure it is safe to pass. -Pass only when given permission by the operator or spotter.

Page 2 ofS

Job Hazards Controls

I. All employees must receive site specific safety orientation prior to beginning work on the project site. Review prime contractor SSHP and sign acknowledgment form.

2. No Chemical Hazards anticipated. 3. Stow all materials in vehicle properly, use appropriate cases and bags. Secure equipment in bed of truck with netting or straps. Do not leave any equipment loose

in the cab or bed or the truck. It can cause property damage or serious injuries to others or yourself by falling-off from vehicle. 4. When securing equipment, watch for pinch points. Straps and netting can get caught on objects and snap back as well as trap a finger if hand placement is not

correct. Use a buddy to help secure equipment when possible. 5. Keep clear area around work area, maintain good housekeeping practices. When possible, use mechanical equipment to perform lifting of heavy objects. When

lifting, follow safe lifting practices. Use the buddy system when lifting. 6. Keep line of site with co-worker and ensure regular verbal contact. If out of the line of site, ensure radio or cell phone contact is established and maintained.

Equipment to be Used Inspection Requirements Training Requirements Utility Vehicles Daily Preventative Maintenance Checks Vehicle & Driver Safety Awareness

Familiarity with the vehicle being operated.

Communications Equipment Daily communications Checks Familiarity with the equipment. Knowledge of Emergency Response Procedures.

Hand Tools Inspect hand tools for serviceability Use hand tools for their intended purposes. Familiarity with the equipment.

Other Training: -Evacuation, Emergency Response & Notification Procedures lAW H&A HASP. -Safe work practices and precautions lAW H&A HASP.

---------------------------------------------------- Page3of5

Equipment to be Used Inspection Requirements Training Requirements -OSHA qualifications and training as required lAW H&A HASP.

All employees, subcontractors, and visitors must sign the Acknowledgement form, in this section, before conducting field activities at this site. By signing this form, CABRERA employees agree that:

I have read this Activity Hazard Analysis and I understand the requirements of the AHA. I will conduct work at this site in accordance with the requirements of the AHA.

By signing this form, subcontractors and visitors agree that: I have read and understood the potential hazards associated with the site. I have read this Activity Hazard Analysis and I understand the requirements of the AHA. I will conduct work at this site in accordance with the requirements of the AHA. I will ensure comoliance with mv comoanv's oolicies on health and

Page 4 ofS

OP SS1 "' Project Planning CABRERA SERVICES

Activity/Work Task: Radiological Monitoring and Surveillance

Project Location: Cherry St. Rad Survey Support

Contract Number: 38563-000

Date Prepared: 2/14/2014

Prepared by (Nameffitle): Sean Liddy

Reviewed by: Sean Liddy, CSP

Competent Person (if applicable): Radiation Technician Notes: (Field Notes, Review Comments, etc.) The following outlines minimum requirements per accordance with the approved HSP for the project site (prepared by H&A). Subcontractors are responsible for performing tasks in accordance with the minimum requirements established for the site and in accordance with their own HS&E policies and procedures. Subcontractors shall review and supplement the AHA with company specific HS&E guidance. Modifications or changes to the AHA should be forwarded to the PM/SSHO and reviewed by all project staff prior to performing the task.

Personal Protective Equipment (PPE):

~Hard Hat ~Safety Glasses

~ Leather Glove 0 Safety Goggles

0 EarMuffs

0 EarPlugs

~ Long Pants/Sleeves

~Coveralls (coated)

Step 2: for each "Hazard" on AHA. Annotate the overall highest RAC at the too of AHA.

0 Kevlar Glove ~Safety Toe Boots ~Traffic Vest 0 Flame Resistant Clothing

0 Inner Glove

~ Outer Glove

0 Face Shield

0 Fall Protection

0 Cooling Vest

0 Welding PPE Other PPE: Modified Level D PPE for dermal orotection in areas of excessive debris.

Safety Equipment:

0 Wide Brim Hat

0 Half/Full Face Respirator

0 Cartridge/Filter Type:

~ First Aid Kit 0 Eyewash Station ~ Eyewash Bottles ~ Fire Extinguisher (A-B-C)

0 Wheel Chocks

0 Pop-up Shade

0 Cargo Net

0 Sunscreen ~Drinking Water

0 Air Horn ~ Trekking Poles 0 Insect Repellent 0 Stretch First Safety First Other Safetv Eauioment: Trekking oole recommended for use to ensure in areas of debris.

Monitoring Procedures and Action Levels (Refer to Section 3.0 of SSHP):

0 PID (I 0.6eV) 0 PID (ll .7eV) 0 Multi-Rae (PID+02, H2S, CO, LEL) 0 PDR (Respirable Dust) 0 PDM (Total Dust) ~ Radiological Meter 0 Personal Air Pump

Chemicals of Concern I Instrumentation accordance with RPP. Consult with Lead RPT for

Job Steps Hazards Controls RAC Site walk/survey to perform Twisting ankles/feet due to Visually inspect area walking. Identify possible hazards such as holes, obstructions inspections and collect surface/subsurface obstructions. protruding from the ground, or debris that may be scattered on the ground. Contact site measurements and data. manager immediately and do not proceed if any conditions are observed that could

make walking in the area unsafe and that cannot be fixed with the equipment or M personnel onsite.

Page 1 ofS

Job

Data collection.

Secure equipment in vehicle.

Hazards

Injuries caused by improper lifting techniques.

Trips/Falls

Falls from ladders

Falls from height

Confmed Spaces

Biologic hazards such as insects, poison ivy, spiders, and snakes.

Exposure to COCs via dust generation during walk over

Injuries caused by improper lifting techniques or stretching.

Twisting ankles/feet due to surface/subsurface obstructions.

falls. Damage to equipment/tools and/or accidents with loose objects.

Pinch points.

Communications

Controls Due to age of building, high potential for holes in walking surface due to weather/rot. A void areas of Use proper bending/lifting techniques by bending and lifting with legs and not with back. Use buddy system to lift heavy objects.

Watch footing and observe ground surface for breaks in elevation, uneven surfaces, loose debris. or other obstructions to cause Ensure proper type of ladder selected for application. Fully extend and lock spreaders on step ladders. Maintain 3 points of contact when ascending/descending.

Avoid areas in which potential fall hazards (?.6ft to lower level) are present.. Use fall protection if exposed to fall ?.6 ft to lower level. Use full body harness and selfretracting lanyard on engineered rail system. Only trained personnel may use.

Be aware of presence of confined spaces on project site and do not enter.

Although not expected to be of concern during winter months, check immediate area for potential hazards such as poison ivy, spiders, wasps, snakes, etc. Use bug repellent,

and snake ""itPr<:/trPk

Avoid contact with contaminated materials. Wear Modified Level D PPE.

Prime to supply Asbestos Trained personnel to assist with identification and avoidance of ACM in the work area.

Use proper bending/lifting techniques by bending and lifting with legs and not with back. Use buddy system to lift heavy objects.

Inspect area before driving and/or walking. Identify possible hazards such as holes, obstructions protruding from the ground, or debris that may be scattered on the ground. Contact the SSHO immediately and do not proceed if any conditions are observed that could make driving/walk in the area unsafe and that cannot be fixed with the equipment or personnel onsite.

Be observant for · old fence lines. Stow all materials in vehicle properly, use appropriate cases and bags. Secure equipment in bed of truck with netting or straps. Do not leave any equipment loose in the cab or bed or the truck. It can cause property damage or serious injuries to others or yourself by falling-off from vehicle. When securing equipment, watch for pinch points. Straps and netting can get caught on objects and snap back as well as trap a fmger if hand placement is not correct. Use a buddy to help secure equipment when possible. Maintain contact with site workers and advise of location of survey, and status. Confirm when

---------------------------------------------------- Page2of5

RAC

Additional Safety Considerations I. Be aware of equipment being used in work zones and maintain adequate safe distances (50ft plus max swing radius). Make eye contact with equipment operators and

receive confirmation prior to approaching.

2. Ensure all personnel have read and acknowledged the AHA. The AHA may be revised daily based on daily de-brief of work activities.

3. Keep line of site with co-worker and ensure regular verbal contact. If out of the line of site, ensure radio or cell phone contact is established and maintained.

Equipment to be Used Inspection Requirements Training Requirements Utility Vehicles, including trucks Daily Preventative Maintenance Checks Vehicle & Driver Safety Awareness

Familiarity with the vehicle being operated.

Communications Equipment Daily communications Checks Familiarity with the equipment. Knowledge of Emergency Response Procedures.

PPE - steel toed boots, hard hat, safety Daily inspection prior to use To be used in accordance with manufacturer's specifications and operator's glasses, high visibility vest, snake gaiters manual

Sodium iodide gamma detector with rate: Daily functional test prior to use Qualified Radiological Protection Technician meter To be used in accordance with manufacturer's specifications and operator's

manual Alpha-Beta-detector with rate:meter Daily functional test prior to use Qualified Radiological Protection Technician

To be used in accordance with manufacturer's specifications and operator's manual

Dose rate meter Daily functional test prior to use Qualified Radiological Protection Technician To be used in accordance with manufacturer's specifications and operator's manual

Hand/Power Tools Inspect hand tools for serviceability Use hand tools for their intended purposes. Use gas powered tools only for intended purposes. Review manufactures instructions. Familiarity with the equipment. Other Training: -Evacuation, Emergency Response & Notification Procedures lAW H&A HASP. -Safe work practices and precautions lAW H&A HASP.

---- ·--_-OSHA qualifications and training as required lAW H&A HASP.

---------------------------------------------------- Page3of5

All employees, subcontractors, and visitors must sign the Acknowledgement form, in this section, before conducting field activities at this site. By signing this form, CABRERA employees agree that:

I have read this Activity Hazard Analysis and I understand the requirements of the AHA. I will conduct work at this site in accordance with the requirements of the AHA.

By signing this form, subcontractors and visitors agree that: I have read and understood the potential hazards associated with the site. I have read this Activity Hazard Analysis and I understand the requirements of the AHA. I will conduct work at this site in accordance with the requirements of the AHA. I will ensure comoliance with mv comoanv's oolicies on health and

---------------------------------------------------- Page4of5


This page intentionally left blank



ATTACHMENTS



ATTACHMENT 2


ACM BAG COUNT -DO SERA TE-ACTIVITY

AND MICROSHIELD RUNS

CABRERA SERVICES INC. ATTACHMENTS

Plastic bag dimension, weight

sphere diameter, in filled weight, lbs

radium activity cone, pCi/g volume, em volume, gallons

radium cone, uCi/cm3 radium total activity, microcurie package density, g/cm3

Note: vary yellow highlight only; calculated answers In green

wt, lbs Pkg uR/hr pCi/g Activ., uCi 20 16 366 13.27 20 8 183 6.63 20 4 91 3.32 20 2 46 1.66 20 0.8 18 0.66

40 16 186 3.38 40 8 93 1.69 40 4 47 0.85 40 2 23 0.42 40 0.8 9 0.17 80 16 98 3.58

80 8 49 1.79

80 4 25 0.9

80 2 12 0.45

80 0.8 5 0.18

filled wt 40 lbs

sphere diameter, in sphere top edge to detector distance, in radium activity cone, pCi/g Material Z is water, package density, g/cm3

Microshield exposure rate, microR/hr

sphere diameter, in sphere top edge to detector distance, in

radium activity cone, pCi/g Material Z is carbon, package density, g/cm3

sphere diameter, in sphere top edge to detector distance, in radium activity cone, pCi/g

24

6

0.153 0.429

24

6

0.153

12 18

Material Z is water, package density, g/cm3 0.153

Microshield exposure rate, microR/hr 0.028

sphere diameter, in 12 sphere top edge to detector distance, in radium activity cone, pCi/g Material Z is water, package density, g/cm3 0.153


400

350

~ 300 ~ t 250 ~

~ 200

~ 150 ~

i 100

~ 50

0 10

filled wt 40 lbs

sphere diameter, in sphere top edge to detector distance, in radium activity cone, pCi/g

Material Z is water, package density,. g/cm3 Microshield exposure rate, microR/hr

sphere diameter, in

sphere top edge to detector distance, in radium activity cone, pCi/g Material Z is carbon, package density, g/cm3 Microshield exposure rate, microR/hr

sphere diameter, in sphere top edge to detector distance, in

24

25

0.153 2.131

24

6 25

0.153 2.192

24

radium activity cone, pCi/g 25 Material Z is carbon, package density, g/cm3 0.306


Assume 2ft dia bags filled with 40 lbs material has volume of 31 gallons and density of 9.54 lbs/ft3 Assume bkg is 8 uR/hr then will see: Gross Reading equates to package pCi/g total uCi

2X's bkg 93 1.69

1.5X's bkg 47 0.85 1.25X's bkg 23 0.42

1.1X's bk& 9 0.17

15 20 uR/hr Above bk&

Case Summary ofRa226 24 in sphere

c I Date

L_ Filename

MicroShield 8.02 Hank Siegrist (8.02-0000)

3 Checked

L_ radium asbestos Waterbury.msd Run Date J Run Time

April10, 2014 11:28:43 AM

Project Info Ra226 24 in sphere

Page 1 of2

Duration 00:00:01

J

24" dia bagged mat'l under 30" table, 5 pCi/g,rho=0.077 6- Sphere

Radius Source Dimensions -- _____] === 30.48 em (1 ft) ===:J

Dose Points =t A X y z #1 45.72 em (1ft 6.0 in) 0.0 em (0 il!) 0.0 em (0 in) I

Shield N Source

Transition

Shields Dimension

1.19e+05 cm3

I Density I

0.077 0.00122

Air Gap ___. __

Material Water

Air Air 0.00122

l Source Input: Grouping Method - Standard Indices

Number of Groups: 25 Lower Energy Cutoff: 0.015 Photons< 0.015: Included

Library: Grove Nuclide Ci Bq J1Cilcm3

Bi-210 2. 7 486e-008 1.0 170e+003 2.3173e-007 Bi-214 4.5068e-008 1.6675e+003 3.7996e-007 Pb-210 2.7497e-008 1.0174e+003 2.3182e-007 Pb-214 4.5068e-008 1.6675e+003 3.7996e-007 Po-210 2.7181e-008 1.0057e+003 2.2916e-007 Po-214 4.5058e-008 1.6672e+003 3.7988e-007 Po-218 4.5077e-008 1.6678e+003 3.8003e-007 Ra-226 1.6678e+003 3.8003e-007 Rn-222 4.5077e-008 1.6678e+003 3.8003e-007

Buildup: The material reference is Source Integration Parameters

Rho (Radial) Angle

Results

Bg/cm3

8.5739e-003 1.4058e-002 8.5773e-003 1.4058e-002 8.4789e-003 1.4055e-002 1.4061 e-002 1.4061 e-002 1.4061 e-002

~ 69 69

IFiuence Rate Fluence Rate Exposure Rate Exposure Rate

file:/ I /C:/Program%20Files/MicroShield%208/Examples/CaseFiles!HTML/radium%20asb... 4/1 0/2014

Case Summary ofRa226 24 in sphere Page 2 of2

. . MeV/cm2/sec MeV/cm2/sec mR!hr mR/hr I Energy (MeV) Activity (Photons/sec) No Buildue With Buildue No Buildup With Buildup 0.015 4.947e+02 6.056e-05 6.989e-05 5.194e-06 5.994e-06 0.05 5.964e+Ol 8.920e-05 1.691e-04 2.376e-07 4.504e-07 0.08 3.844e+02 9.719e-04 1.709e-03 1.538e-06 2.705e-06 0.1 2.264e+OO 7.277e-06 1.187e-05 1.113e-08 1.816e-08 0.2 1.796e+02 1.213e-03 1.636e-03 2.140e-06 2.887e-06 0.3 3.44le+02 3.585e-03 4.479e-03 6.800e-06 8.495e-06 0.4 6.381e+02 9.042e-03 1.083e-02 1.762e-05 2.110e-05 0.5 2.979e+Ol 5.356e-04 6.240e-04 1.051e-06 1.225e-06 0.6 8.040e+02 1.755e-02 2.007e-02 3.426e-05 3.917e-05 0.8 1.576e+02 4.670e-03 5.200e-03 8.882e-06 9.890e-06 1.0 5.221e+02 1.959e-02 2.148e-02 3.612e-05 3.960e-05 1.5 3.175e+02 1.827e-02 1.954e-02 3.073e-05 3.287e-05 2.0 4.463e+02 3.471e-02 3.664e-02 5.367e-05 5.666e-05

Totals 4.380e+03 1.103e-Ol 1.225e-01 1.983e-04 2.211e-04

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E Date

Filename


Checked

radium asbestos Waterbury.msd Run Date J Run Time

A ril10, 2014 12:03:29 PM

Project Info Ra226 24 in s here

Duration 00:00:01

24" dia bagged mat'l under 30" table, 5 pCi/g,rho=0.153 6- S here

A #1

~--

Source Dimensions --=.___] Radius -) 30.48 em (1 ft) ===:=J

x Y -r-=-z Dose Points ~

45.72 £!!!_(1 ft 6.0 in) 0.0 em 0 in) T O~m (0 in)

r Shield N Shields

Dimension 1.19e+05 cm3

Material »;~~ji ~ Source Transition Air Gap

Nuclide Bi-210 Bi-214 Pb-210

Water Air Air

0.00122 0.00122

Source Input: Grouping Method - Standard Indices Number of Groups: 25

Ci 5.4972e-008

Lower Energy Cutoff: 0.015 Photons< 0.015: Included

Library: Grove B

2.0340e+003 3.3350e+003 2.0348e+003 3.3350e+003 2.0 114e+003 3.3343e+003 3.3357e+003 3.3357e+003 3.3357e+003

J1Ci/cm3

4.6345e-007 7.5991e-007 4.6364e-007 7.5991e-007 4.5832e-007

Bq/cm3

1. 7148e-002

2.8122e-002

-

__ _,

Buildup: The material reference is Source Inte ration Parameters [ ----------r-----------~

Rho (Radia;.;_l)!.-------------+- 69 An le

I Results

~------~---------.,-F-lu-e-nceRate F-1-u-en_c_e_R_a_t~e~E-x_p_o_s-ur_e_R_a_t_erE_x_p_o-su_r_e_R_a_t~e

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. . MeV/cm1/sec MeV/cm1/sec Energy (MeV) Activity (Photons/sec) No Buildup With Buildup

0.015 9.895e+02 6.285e-05 7.283e-05 - -0.05 1.193e+02 1.339e-04 3.651e-04 0.08 7.689e+02 l 1.516e-03 3.974e-03 0.1 4.527e+OO --t 1.150e-05 2. 709e-05

- -0.2 3.592e+02 1.988e-03 3.461e-03 0.3 6.882e+02 6.011e-03 9.087e-03 0.4 0.5 0.6 0.8 1.0 1.5 2.0

Totals - ..__

1.276e+03 5.958e+01 1.608e+03 3.152e+02 1.044e+03 6.349e+02 8.925e+02 8.760e+03

1.541e-02 9.241e-04 3.059e-02 8.262e-03 3.507e-02

_.~.......;;3..;.;. 3;..;;.33e-02

6.411e-02 1.974e-Ol

2.161e-02 1.233e-03 3.941e-02

7.116e-02 2.403e-Ol

Page 2 of2

mR!hr mR!hr No Buildup With Buildup 5.391e-06 6.247e-06 3.568e-07 9.725e-07 2.399e-06 6.289e-06 1.759e-08 4.144e-08 3.509e-06 6.108e-06 1.140e-05 1.724e-05 3.002e-05 4.211e-05 1.814e-06 2.420e-06 5.970e-05 7.693e-05 1.572e-05 1.928e-05 6.464e-05 7.707e-05 5.608e-05 6.379e-05 9.914e-05 1.100e-04 3.502e-04 4.285e-04

file:/ //C:/Program%20Files/MicroShield%208/Examples/CaseFiles/HTML/radium%20asb... 4/1 0/2014


Date

Filename


By Checked

E radium asbestos Waterbury.msd Run Date 1 Run Time

April 10, 2014 11:22:10 AM

Project Info Ra226 24 in sphere

Page 1 of2

Duration 00:00:01

24" dia bagged mat'! under 30" table, 5 pCi/g,rho=0.306 6- Sphere

t: Radius ..--

A #1 45.72 em

Shield N Source

Transition Air Gap

Nuclide Bi-210 Bi-214 Pb-210 Pb-214 Po-210 Po-214 Po-218 Ra-226 Rn-222

Source Dimensions ::=1 30.48 em (1 f0 Dose Points -=1

X y z 1 ft 6.0 in) 0.0 em 0 in) 0.0 em (0 in)

Shields Dimension Material Density ~

1.19e+05 cm3 Water 0.306 Air 0.00122 Air 0.00122

Source Input: Grouping Method - Standard Indices Number of Groups: 25

Lower Energy Cutoff: 0.015 Photons< 0.015: Included

Library: Grove Ci Bq ,...ci/cm3

1.1 066e-007 4.0943e+003 9.3293e-007 1. 8144e-007 6. 7133e+003 1.5297e-006 1.1 070e-007 4.0959e+003 9.3329e-007 1. 8144e-007 6. 7133e+003 1.5297e-006 1.0943e-007 4.0490e+003 9.2259e-007 1. 8140e-007 6. 7119e+003 1.5294e-006 1.8148e-007 6.7147e+003 1.5300e-006 1.8148e-007 6. 7146e+003 1.5300e-006 1.8148e-007 6.7147e+003 1.5300e-006

Bq/c~ 3 .4518e-002 5.6599e-002 3.4532e-002 5.6599e-002 3 .4136e-002 5.6587e-002 5.6610e-002 5.6609e-002 5.6610e-002

I ----====-

~ Buildup: The material reference is Source

Integration Parameters Rho (Radial) 69

Angle 69

Results

IFluence Ratel Fluence Rate !Exposure Ratef Exposure Rate

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. . MeV/cm2/sec MeV/cm2/sec mR/hr mR/hr I Energy (MeV) Activity (Photons/sec) No Buildup With Buildup No Buildup With Buildup 0.015 1.992e+03 6.376e-05 7.397e-05 5.469e-06 6.344e-06 0.05 2.401e+02 1.711e-04 6.547e-04 4.559e-07 1.744e-06 0.08 1.548e+03 2.028e-03 8.400e-03 3.209e-06 1.329e-05 0.1 9.113e+OO 1.562e-05 5.807e-05 2.390e-08 8.884e-08 0.2 7.232e+02 2.841e-03 7.181e-03 5.014e-06 1.267e-05 0.3 1.385e+03 8.872e-03 1.797e-02 1.683e-05 3.409e-05 0.4 2.569e+03 2.331e-02 4.204e-02 4.542e-05 8.190e-05 0.5 1.199e+02 1.425e-03 2.369e-03 2.798e-06 4.651e-06 0.6 3.237e+03 4.793e-02 7.529e-02 9.355e-05 1.469e-04 0.8 6.344e+02 1.327e-02 1.922e-02 2.525e-05 3.655e-05 1.0 2.102e+03 5.742e-02 7.913e-02 1.058e-04 1.459e-04 1.5 1.278e+03 5.643e-02 7.169e-02 9.493e-05 1.206e-04 2.0 1.797e+03 1.109e-01 1.349e-01 1.715e-04 2.086e-04

Totals 1.763e+04 3.247e-Ol 4.590e-01 5.703e-04 8.134e-04

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CABRERA. RADIOLOOICAl.• ENCINEF$1NC• REt.IEOIAnONProtection Plan (RPP). Elevated levels of material will have an isotopic analysis to ensure ... Please contact Mike Winters at